D. A. DESAI, J. ( 1 ) THIS appeal by Judges summons is preferred by the Petlad Nagarpalika against the decision of the Official Liquidator of Rajratna Naranbhai Mills Company Limited (in liquidation) (hereinafter referred to as the Company) dated 14th August 1972 rejecting the claim for priority in payment claimed by the petitioner in respect of an amount of Rs. 4 141 P. Petitioner claimed the aforementioned amount from the company. The Liquidator admitted the claim against the company but declined to give priority in payment as claimed by the petitioner under sec. 530 (1) (a) of the Companies Act. Aggrieved by the latter part of the order refusing priority in payment the petitioner has taken out this Judges summons under rule 164 of the Companies (Court) Rules challenging the order of the Liquidator. Priority in payment was claimed on the allegation that the petitioner is a local authority and the amount represents the revenue payable by the Company to the local authority. Petitioner is also a licensee for the supply of electricity and the company was the consumer. Petitioner presented the bill for the energy consumed by the company for the months of April May and June 1967 in the aggregate amount of Rs. 4148-69 P. and this amount was outstanding at the relevant date. The company had two independent connections namely ordinary consumer connection and connection for motive power. The break-up of the amount was as under :-MOTIVE power. Rs. 2278-74 P. Rs. 178-93 Electricity duty. LIGHTS and fans. Rs. 1862-95 P. Rs. 450-90 Electricity duty. The amount of electricity duty payable by the licensee to the Government and to be collected from the consumer was Rs. 629-83. One Ramchandra Ganesh Padhye Electrical Engineer Petlad Nagar Palika filed his affidavit in proof of the claim and claimed priority in payment. The liquidator accepted the claim but rejected the claim for priority in payment for the whole or any part of the amount therein. However at the hearing of this summons it was conceded and very rightly that out of the total claim the amount of Rs. 629-83 being the amount of electricity duty payable to the State Government under sec. The liquidator accepted the claim but rejected the claim for priority in payment for the whole or any part of the amount therein. However at the hearing of this summons it was conceded and very rightly that out of the total claim the amount of Rs. 629-83 being the amount of electricity duty payable to the State Government under sec. 4 of the Bombay Electricity Duty Act 1858 would be a tax payable by the consumer through the licensee to the State Government and as that amount was outstanding and had become due and payable within 12 months next before the relevant date therefor it would be entitled to priority in payment The liquidator also conceded again in my opinion rightly that notice charges payable in the amount of Rs. 4/to the State Government would be entitled to priority in payment. Therefore it was conceded that out of the total claim an amount of Rs. 633-83 P. would be entitled to priority in payment. The liquidator contested the priority for the balance of the amount. ( 2 ) THE company was ordered to be wound up by an order made on 26 June 1967. The liquidator after obtaining directions of the Court invited the creditors of the company to prove their debts or claims and simultaneously to establish any title they may have to priority under sec. 530. ( 3 ) MR. M. 1. Patel learned Advocate who appeared for the petitioner urged that Petlad Nagar Palika is a local authority and the amount payable to the local authority would be revenue of the local authority and as the amount was outstanding on the relevant date and had become due and payable within 12 months next before the relevant date therefore it would be entitled to priority in payment. Sec. 530 (1) (a) reads as under :-530 (1) Preferential payments. In a winding up there shall be paid in priority to all other debts (A) all revenues taxes cesses and rates due from the company to the Central or a State Government or to a local authority at the relevant date as defined in clause (c) of sub-sec. (8) and having become due and payable within the twelve months next before the date;clause (c) of sub-sec. (8) of sec. (8) and having become due and payable within the twelve months next before the date;clause (c) of sub-sec. (8) of sec. 530 defines the relevant date to mean in the case of a company ordered to be would up compulsorily the date of the appointment (or first appointment) of a provisional liquidator or if no such appointment was made the date of the winding up order unless in either case the company had commenced to be wound up voluntarily before that date. Therefore the relevant date for the purpose of present inquiry would be the date on which winding up order was made namely 26 June 1967. In order to claim priority by invoking clause (8) of sub-sec. (1) of sec. 530 it must be shown that revenues taxes cesses and rates due from the company to the local authority were due from the company at the relevant date and had become due and payable within 12 months next before that date. Now there is no dispute in this case that the amount claimed by the petitioner was due at the relevant date and there is equally no dispute in this case that it had become due and payable within 12 months next before the relevant date. ( 4 ) CONTROVERSY centres round the contention whether the amount claimed by the petitioner would be revenue payable by the company to the local authority. It is conceded that except the amount of electricity duty included in the claim the balance of the amount was not the amount of any tax cess or rate but it was contended that the amount represented the revenue of the local authority and it was payable by the company to the local authority as revenue. ( 5 ) PETLAD Nagar Palika undoubtedly is a local authority. At one stage Mr. Ashok L. Shah learned Advocate for the liquidator attempted to urge that electricity department of the Nagarpalika would not be a local authority. In other words it was contended that even if Petlad Nagarpalika is a local authority its electricity department is wholly independent of its constitution as a local authority and any claim in electricity department would not be a claim by way of revenue of a local authority. In other words it was contended that even if Petlad Nagarpalika is a local authority its electricity department is wholly independent of its constitution as a local authority and any claim in electricity department would not be a claim by way of revenue of a local authority. It is undoubtedly true that the character of each department of a local authority can be safely examined as was done by the Supreme Court in The Corporation of the City Nagpur v. Its employees A. I. R. 1960 S. C 675. Question arose whether Nagpur Corporation was an industry within the meaning of the C. P. and Berar Industrial Dispute Settlement Act 1947 It was in terms held that looking to the service rendered by the Corporation if it complies with the conditions implicit in the definition it will be an industry within the meaning of the definition in the Act. After having observed thus the Supreme Court examined the services rendered by the Corporation in its various departments including Sewage Department and Health Department and held that Health Department looks after scavanging sanitation control of epidemics control of food adulteration etc. and therefore the Department satisfies the other tests laid down by the Supreme Court and is an industry within the meaning of the word industry. Therefore in a given case it may become necessary to examine the services rendered by different departments. But in order to find out whether any department of a local authority is itself a local authority or not it would not be proper to examine the functions and duties of different departments and to conclude that while one department would be a local authority the other would not be a local authority. Expression local authority has been defined in the sec. 3 (26) of the Bombay General Clauses Act 1904 to mean a municipal corporation municipality local board body of port trustees or commissioners or other authority legally entitled to or entrusted by the Government with the control or management of a municipal or local fund. Sec. 3 (31) of the General Clauses Act 1897 defines local authority to mean a municipal committee district board body of port commissioners or other authority legally entitled to or entrusted by the Government with the control or management of a municipal or local fund. Sec. 3 (31) of the General Clauses Act 1897 defines local authority to mean a municipal committee district board body of port commissioners or other authority legally entitled to or entrusted by the Government with the control or management of a municipal or local fund. A Municipality set up under the Gujarat Municipalities Act or deemed to have been set up under the Gujarat Municipalities Act would be a local authority and Petlad Nagarpalika is a municipality deemed to have been set up under the Gujarat Municipalities Act and therefore it is a local authority. It had obtained a licence for distribution and supply of electricity. Its electricity department is a part of the local authority and therefore it is not correct to say that electricity department of the Petlad Nagarpalika is not included in the comprehensive expression local authority. Same conclusion can be reached by approaching the matter from a slightly different angle. The income of the electricity department could not be said to be an income of the department alone. It would be the income of the municipality. Income of one department of a municipality is the income of the as a whole because one can envisage that one department may be a wholly spending department and another department may be a wholly earning department and it would not be correct to examine the income and expenditure department-wise. (vide Baroda Borough Municipality v. Its workmen A. I. R. 1957 S. C 110 ). Therefore even though for the purpose of finding out whether one or the other department of a local authority may or may not fall within the definition of the word industry as used in the Industrial Disputes Act or such other analogous statute when it comes to finding out whether each department of the municipality is covered by the expression local authority or not proper approach would be to treat all the departments of the municipality as the departments of a local authority because municipality itself is a local authority. ( 6 ) QUESTION then is whether the claim preferred by the petitioner constitutes revenue of the local authority ? If the claim constitutes revenue of the local authority and if it was due at the relevant date and had become due and payable within 12 months next before the relevant date it would be entitled to priority in payment. ( 6 ) QUESTION then is whether the claim preferred by the petitioner constitutes revenue of the local authority ? If the claim constitutes revenue of the local authority and if it was due at the relevant date and had become due and payable within 12 months next before the relevant date it would be entitled to priority in payment. Other two conditions for attracting sub-clause (a) of sec. 530 (1) are already satisfied and therefore the limited question is whether the amount could be said to be revenue of the local authority ? ( 7 ) WORD revenue has ordinarily been understood to mean something payable to the Government for the use and occupation of land as all lands belong to the State. Anyone who uses the land on agreeing or undertaking to pay something for the use of the land the amount so paid becomes or is styled as revenue of the State. Word revenue was also referred to include every sum annually paid to Government by the proprietor of any estate or tenure in respect thereof. (vide Haji Buksh Elahi v. Durlay Chandra Kar 14 Bom. L. R. 1963 at P. 1070 ). Commencing from this general import of the word revenue it has often been said that income of the State from any source is revenue of the State. This approach commended itself and was unquestionable till the State was conceived as Police State. Till then land revenue was the major if not only source of revenue. When the State was conceived as Police State its normal functions were maintenance of law and order enforcing orderly and regulatory behaviour in the society. But once the State ceased to be merely a police State with the advent of the concept of a welfare State activities of the State increased many-fold. Maintenance of Law and Order became secondary function of the State activity primary activity being socio-economic justice to the citizens and just distribution of the national wealth and control of material resources of the community to be so distributed as to best subserve the common good and to prevent concentration of wealth and means of production in the hands of few to the common detriment. Attempt was to set up an egalitarian society as conceived in the directive principles of State policy enunciated in Part IV of our Constitution. Attempt was to set up an egalitarian society as conceived in the directive principles of State policy enunciated in Part IV of our Constitution. To achieve this goal the State had to undertake number of industrial and commercial activities. Large amounts were spent on the planned industrial growth and the State itself became the biggest industrial magnate State started earning income from its investment in industrial enterprises. Now should the concept of revenue remain constant in this ever changing concept of activity of the State ? If the old and time honoured concept of revenue was to be adhered to obviously one would always refer back to the notion where revenue represented the income of the State for permitting use of land. Indisputably concept and content of revenue must also change. What should be the meaning that should be assigned to word revenue in sub-clause (a) of sec. 530 (1) ? Should it be construed so wide as to include all income derived by State or a local authority from any source I Should it be construed so narrow as to confine its meaning to the time honoured practice of relating it to the income derived by the State for permitting use of land ? Both approaches appear to be wide off the mark in the present context because the old concept of police State is consigned to the limbo of oblivion and the concept of welfare State has become all embracing. The State has entered into industrial and commercial activity on a very large scale and if income from such activities derived by the State was to be treated revenue and was therefore to be granted priority in payment it would be highly discriminatory and inconsistent with the doctrine of pari passu distribution of assets of an insolvent company statutorily recognised in sec. 511 of the Companies Act. ( 8 ) A few illustrative cases can be examined here. In re Dehra Dun Mussorie Tramway A. I. R. 1930 All. 884 priority in payment was claimed by the Telegraph Department which included the cost of moving telephone lines rent of telephone lines telephone bills etc. Referring to the definition of the word revenue in Wartons Law Lexicon Edn. ( 8 ) A few illustrative cases can be examined here. In re Dehra Dun Mussorie Tramway A. I. R. 1930 All. 884 priority in payment was claimed by the Telegraph Department which included the cost of moving telephone lines rent of telephone lines telephone bills etc. Referring to the definition of the word revenue in Wartons Law Lexicon Edn. 13 meaning income annual profit received from land or other funds also the profits or fiscal prerogatives of the Crown and the meaning of the word revenue given in Murrays Dictionary to mean return yield or profit of any lands property or other important source of income it was held that revenue must not necessarily be taken to be ejusdem generis with the words that come after it and it consequently means income. However having said this priority was not granted for the whole amount but for a small amount which constituted rent of the telephone lines and charge of the trunk-calls. Now if revenue was to mean income of the Government from any source priority should have been granted for the entire claim. It has not been done and it would give some ides about connotation of the expression revenue. In Secretary of State for India v. Punjab Industrial Bank Limited (1931) Comp. Cas. 303 the fees payable to the Registrar of Joint Stock Companies a Central Government Officer for the action taken by him in discharge of his official duty under sec. 138 by appointing Shaikh Din Mohammad to investigate the affairs of the Punjab Industrial Bank Limited was held not to be entitled to priority in payment. Thus certain payment to Central Government may not h included in the expression revenue. In Northern Bengal Co. Ltd. In re. 1937 Comp. Cas. 470 claim for priority was rejected observing that debt in respect of which priority is claimed is a trade debt and not entitled to priority. Thus trade debt did not form part of the revenue of the Government. In K. Chandu v. The Mysore State Electricity Board and others (1962) 32 Comp. Cas. 168 claim of the State Electricity Board and the State Housing Board for priority in payment was rejected. On facts the case is very much similar to the one before me. Debt in that case was due to the Director of Sericulture for supply of silk worm eggs to a silk manufacturing company. Cas. 168 claim of the State Electricity Board and the State Housing Board for priority in payment was rejected. On facts the case is very much similar to the one before me. Debt in that case was due to the Director of Sericulture for supply of silk worm eggs to a silk manufacturing company. Priority was claimed on the allegation that debt was due to the department of the Government and it would constitute revenue of the Government. Claim for priority was rejected on the ground that the State cannot claim priority for supplying goods and receiving price thereof it being a commercial activity of the State and which income of the State would not constitute revenue of the State. In the State v. Pure Milk Supply Co. Ltd. (1963) 33 Comp. Cas. 116 the Governments claim consisted of the loan advanced by it to the company under the State Aid to Industries Act 1935 Claim for priority was negatived on the observation that such a claim would not constitute revenue of the State and no priority can be granted except in respect of those dues recognised under sec. 530. Lastly I would refer to Union of India v. Ladulal Jain A. I. R. 1963 S. C. 1681 wherein running of railway was treated as commercial activity of the State. Supply of electricity cannot stand on footing higher than that. The test laid down by the Court was that it is immaterial and irrelevant who runs the activity it is the nature of the activity which is decisive of the matter. If supply of electricity by a private licensee would render the claim of such licensee for consumption of electricity an unsecured debt so would it be even if the electrical energy is supplied by a licensee which is a municipality and hence a local authority. Activity which is commercial in the hand of an individual does not cease to be commercial merely because local authority carries on the same. ( 9 ) WORD revenue has been used in conjunction with the words tax cess and rate. Priority in payment is sought to be given to all revenues taxes cesses and rates payable to the Central or State Government or to a local authority. Should the word revenue used in clause (a) take its colour from the words just following namely taxes cesses and rates ? Priority in payment is sought to be given to all revenues taxes cesses and rates payable to the Central or State Government or to a local authority. Should the word revenue used in clause (a) take its colour from the words just following namely taxes cesses and rates ? Now it is quite well known that tax cess or rate is a compulsory exaction by the Government or a local authority and does not depend upon the volition of the party. Should word revenue take its colour from the words used in conjunction with it. In other words should its meaning be cut down by referring to the analogous words used in conjunction with it ? Now it is a well known canon of construction that when two or more words which are susceptible of analogous meaning are coupled together they are understood to be used in their cognate sense. They take as it were their colour from each other that is the more general is restricted to a sense analogous to a less general. The maxim Ejusdem Generis is only an illustration of the maxim noscuitur a sociis (vide Dr. D. M. Surti v. State of Gujarat A. I. R. 1969 S. C. 63 at p. 66 ). Where the intention of the legislature in associating wider words with the words of narrower significance is doubtful or otherwise not clear that the present rule of construction of nocuitur a sociis can be usefully applied. It can only be applied where the meaning of the words of wider import is doubtful; but where the object of the legislature in using wider words is clear and free of ambiguity the rule of construction in question cannot be pressed into service (vide State of Bombay v. Hospital Mazdoor Sabha A. I. R. 1960 S. C. 610 ). According to a well established rule used in the construction of statutes general terms following particular ones apply only to such persons or things as are ejusdem generis with those compreheaded in the language of the Legislature (vide R. v. Cleworth (1864) 4 B. and S. 927 per Cockburn C. J. at p. 932 ). According to a well established rule used in the construction of statutes general terms following particular ones apply only to such persons or things as are ejusdem generis with those compreheaded in the language of the Legislature (vide R. v. Cleworth (1864) 4 B. and S. 927 per Cockburn C. J. at p. 932 ). In other words it would mean that the general expression is to be read as comprehending only things of the same kind as that designated by the preceding particular expression unless there is something to show that a wider sense was intended. Maxim ejusdem generis is applied where general term follows the expression of narrower connotation preceding it. On the other hand where two or more words which are susceptible of analogous meaning are conpled together noscuitur a sociis they are understood to be used in their cognate sense. In other words it would mean that connotation of the general expression preceding more specific would be cut down to the con notation of the expression following general expression unless of course the legislature intended and expressed itself by defining the words in wider amplitude for the purpose of covering a wider field. Meaning so given by the Legislature for certain purposes cannot be cut down by refer ring to other words in conjunction with which the expression is used. If the legislature intended to give wider meaning for certain defined purposes it would be unwise to cut down the meaning merely by invoking the doctrine of nocuitur a sociis (vide Khatija Abdulla v. National Tobacco Co. 13 Guj. L. R. 205.) ( 10 ) IN order to correctly gauge the connotation in which word revenue as used in sub-clause (a) of sec. 530 (1) it is necessary to find out the legislative intendment in giving priority to the claims of the Central and State Government and a local authority and the extent to which priority can be granted. It has its genesis in the common law doctrine giving priority to Crown debts in payments of debt of an individual. This doctrine of common law received judicial recognition in India and therefore it was treated as law in force in the territory of India at the relevant time within the meaning of Article 372 (1) of the Constitution. It has its genesis in the common law doctrine giving priority to Crown debts in payments of debt of an individual. This doctrine of common law received judicial recognition in India and therefore it was treated as law in force in the territory of India at the relevant time within the meaning of Article 372 (1) of the Constitution. The basic justification for the claim for priority of State debts rests on the well recongised principle that the State is entitled to raise money by taxation because unless adequate revenue is received by the State it would not be able to function as a sovereign Government at all. It is essential that as a sovereign the State should be able to discharge its primary governmental functions and in order to be able to discharge such function efficiently it must be in possession of necessary funds and -this consideration emphasises the necessity and the wisdom of conceding to the State the right to claim priority in respect of its tax dues (vide Builders Supply Corporation v. Union of India 1965 S. C. 1081 ). In Bank of India v. John Bowman A. I. R. 1955 Bom. 305 Chagla C. J. (as he then was) observed that the priority given to the Crown is not on the basis of its debt being a judgment-debt or a debt arising out of statute but the principle is that if the debts are of equal degree and the Crown and the Subject are equal the Crowd right will prevail over that of the subject. The obiter observation of the Madras High Court in Manickam Chettiar v. Income Tax Officer Madura A. I. R. 1938 Madras 360 was disapproved by observing that the weight of authority in support of the applicability of the common law doctrine in regard to tax dues in this country is so strong that no significance can be attached to these obiter observations. In Collector of Aurangabad and another v. Central Bank of India and another A. I. R. 1967 S. C. 1831 observation of Chagla C. J. hereinabove quoted was approved observing that the English common law doctrine of the priority of Crown debts has been given recognition in the territory known as British India prior to 1950 in regard to the recovery of tax dues in priority to other private debts of the tax-payer. However this common law doctrine of priority of Crown debt need not be enforced in this petition because the case is governed by specific statutory provision granting priority enacted in sec. 530 (1) (a) and effect would have to be given to it. ( 11 ) WHEN a private creditor recovers his dues from the company amount undoubtedly comes into his pocket for his own benefit. When certain taxes cesses or rates payable to the Central or State Government or local authority are collected the amount comes into the public coffer and is used for the benefit of the public at large. In giving priority the intention of the legislature appears to be to put common good on a slightly higher pedestal to the private good in the distribution of assets of an insolvent company. If a private creditor is not able to recover his dues it would be a loss of an individual and he alone may suffer. If the Government or local authority is unable to recover its dues such as a tax cess or rate which are compulsorily payable it would be common good that would suffer and damage if any would be to the society as a whole. After all if the State for setting up a welfare State is to carry on its activities committed to render economic and social justice it must have funds; and therefore some preference may be given to the Government in collection of its dues. Viewing it from this angle that the special procedure prescribed in Revenue Recorery Act as well as sec. 117 of the Bombay Land Revenue Code was held valid and not offending the vice of discrimination under Article 14 of the Constitution of India. (vide Special Civil Applications Nos. 266 of 1970 788 of 1969 and 1374 of 1970 decided on 7/9th December 1970 by the High Court of Gujarat in M/s. Ramkrishna Durgaprasad and Others v. State of Gujarat ). Question however is whether such a priority should be given to Government in respect of its claim emanating from every source. Once the State has entered the field of industry and commerce it may have income from its industrial undertakings or commercial activity. Question however is whether such a priority should be given to Government in respect of its claim emanating from every source. Once the State has entered the field of industry and commerce it may have income from its industrial undertakings or commercial activity. If the expression revenue was to be understood in the sense of income from any source income of the State Government from its industrial and commercial activity would also constitute its revenue and may be entitled to priority in payment. That would be complete ante-thesis of old concept of revenue which meant payment to the government for the use of the land on the footing that all lands belong to the State. Legislature has however manifested its intention in not leaving the word revenue standing by itself but the same has been followed by more specific words such as taxes cesses and rates. General expression has been followed by words of specific connotation and there is nothing in the language of sub-clause (a) which would mean that the legislature used the word revenue in its widest amplitude and did not want its meaning to be cut down. Even collection of tax when it goes to the coffer of the State it would constitute revenue of the State so also collection of the cess and rates. If by using expression revenue the Parliament wanted to provide for priority for income derived by the State from whatever source it was absolutely not necessary to use the words taxes cesses and rates following the word revenue. But it appears that the legislature wanted to completely manifest its intention by providing that the word revenue shall be understood in the narrower sense though not in the narrowest sense. Tax generally speaking is a compulsory exaction not depending upon the volition of the parties liable to pay and so is the case with the cess and rate. Now if all these words which are susceptible of analogous meaning are coupled together on the principle of noscuitur a sociis they are understood to be used in their cognate sense. Viewed from this angle revenue can only mean compulsory exaction which may include even fee for service rendered such as water rate or sanitary cess. It may include rate on building. Viewed from this angle revenue can only mean compulsory exaction which may include even fee for service rendered such as water rate or sanitary cess. It may include rate on building. It may include everthing which may be a compulsory exaction not depending upon the volition or free will of the party from whom it is sought to be collected. But expression revenue cannot be so expanded as to include all income of the State coming from whatever source. If Government were to advance a loan if Government were to stand as guarantor if Government were to derive its income from the commercial and industrial activities such money coming in the hands of the Government may loosely be called revenue. But it does not constitute revenue within the meaning of the expression in sub-sec. (1) (a) of sec. 530. Word revenue must take its colour from the other words used in the clause each one of which is susceptible of analogous meaning and each one of them should be understood to have been used in its cognate sense. Each takes its colour from the other with the result that meaning of the more general being restricted to the sense analogous to that of the less general. Interpreting the meaning of the word revenue in this manner it would be quite clear that expression revenue must be understood in the sense of compulsory exaction or in contradistinction to the income coming in the coffer of the Central or State Government or local authority from its commercial or industrial activities. ( 12 ) NOW Petlad Nagarpalika-petitioner-in this case was a licensee under the Indian Electricity Act. It was supplying electricity within the area of the licence. It was entitled to charge for the energy consumed by the customer. Under sec. 4 of the Bombay Electricity Duty Act it was bound to levy and collect duty for and on behalf of the State Government and payable to the State Government from the consumers at the rate prescribed under the Act. Any private individual if he had carried on the activity of supplying energy as a licensee it would have been if it was not generating electricity a commercial activity in the hands of such individual. So would be the case of Municipality as licensee under the Indian Electricity Act. Any private individual if he had carried on the activity of supplying energy as a licensee it would have been if it was not generating electricity a commercial activity in the hands of such individual. So would be the case of Municipality as licensee under the Indian Electricity Act. When a bill is presented for electrical energy consumed in normal grammatical parlance it means payment for the goods supplied. Goods in its generic sense would include electrical energy. If goods are supplied and payment is insisted upon failure to pay would render the vendor of the goods an unsecured creditor of the company. Such would be the position of the municipality when consumer namely company in liquidation failed to pay the bill when presented to it. It would be a payment to the municipality for the goods supplied and the amount received or receivable would not be revenue payable to the local authority within the meaning of the expression in sec. 530 (1) (a ). ( 13 ) IT is thus crystal clear that the claim of the petitioner which is undoubtedly a local authority and which was due on the relevant date and which became payable within 12 months next before the relevant date yet it being not revenue payable to local authority whole of it would not be entitled to priority but only portion of it which constitutes electricity duty payable by the licensee to the State Government would be entitled to priority. ( 14 ) ACCORDINGLY this appeal is partly allowed and the Liquidator is directed to admit the claim in the amount of Rs. 633-83 P payable by the company to the petitioner as entitled to be paid in priority and balance of the claim is not entitled to priority and rejection for priority for the balance of the claim by the Liquidator is correct and is hereby confirmed. In the facts and circumstances of the case there would be no order as to costs. Appeal partly allowed. .